On July 10, 2017, the OECD released its 2017 Edition of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations.
This 2017 edition of the OECD Transfer Pricing Guidelines contains all the changes and modifications stemming from the BEPS initiative which officially started in 2013.
The end result is a whopping 600-plus pages document which now includes the latest OECD guidance on comparability, transfer pricing methods, intangibles and transfer pricing, to name a few. History buffs may recall that it all started with a 100-pages document in 1979.
At this time, the OECD Transfer Pricing Guidelines now comprises 9 fully-packed chapters with “guidance” and added examples.
Will the upcoming Chapter 10 pertains to formulary apportionment when everything else fails? Only time will tell.
But with more significant changes expected in the upcoming years regarding hard-to-value intangibles and the use of profit split methods for transfer pricing, this may not really be a stretch of the imagination after all…
The OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2017 are available here.
To know more about BEPS, check the library on BEPS and Transfer Pricing which is available here.
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